Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Refund of Cenvat credit - exported without payment of duty but not under the bond or the letter of undertaking (LUT) - The appellant was not entitled to claim the Cenvat credit of duty paid on imports used in manufacture of the product to which nil rate of duty was applicable. In such situation if some credit has been availed Rule 14 should have first been applied by the department - In the present case, it is not coming apparent as to whether said rule 14 has been complied with by the department prior rejecting the impugned refund. - AT
Refund of Cenvat credit - exported without payment of duty but not under the bond or the letter of undertaking (LUT) - The appellant was not entitled to claim the Cenvat credit of duty paid on imports used in manufacture of the product to which nil rate of duty was applicable. In such situation if some credit has been availed Rule 14 should have first been applied by the department - In the present case, it is not coming apparent as to whether said rule 14 has been complied with by the department prior rejecting the impugned refund. - AT
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